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Home My WebLink About08-5314FRIEDMAN & KING, P.C. Richard S. Friedman, Esquire ID #07176 3820 Market Street Camp Hill, PA 17011 Tel.: (717) 236-8000/Fax: (717) 236-8080 E-mail: friedmanandkingQhotmail.com Attorney for Plaintiff KIMBERLY H. CICCOCIOPPO, Plaintiff V. FRANCIS A. CICCOCIOPPO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6 FK - 5_31 '/ Cj t / te_fpt CIVIL ACTION - LAW CUSTODY/VISITATION COMPLAINT FOR CUSTODY 1. The Plaintiff is Kimberly H. Ciccocioppo, residing at 340 Blacklatch Lane, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. The Defendant is Francis A. Ciccocioppo, residing at 1345 Sconsett Way, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff seeks custody of the following children: NAME PRESENT RESIDENCE Samantha E. Ciccocioppo Dominic A. Ciccocioppo 340 Blacklatch Lane Camp Hill, PA 17011 340 Blacklatch Lane Camp Hill, PA 17011 The children were not born out of wedlock. AGE DOB 17 years 12 years 08/24/1991 07/15/1996 The children are presently in the custody of Mother, who resides at 340 Blacklatch Lane, Camp Hill, PA 17011. During the past five (5) years, the children have resided with the following persons and at the following addresses: NAME RESIDENCE DATE Kimberly H. Ciccocioppo 340 Blacklatch Lane 03/01/2008 to present Camp Hill, PA 17011 Kimberly H. Ciccocioppo 340 Blacklatch Lane 02/1998 to 03/01/2008 Francis A. Ciccocioppo Camp Hill, PA 17011 The mother of the children is Kimberly H. Ciccocioppo, currently residing at 340 Blacklatch Lane, Camp Hill, PA 17011. She is married to father. The father of the child is Francis A. Ciccocioppo, currently residing at 1345 Sconsett Way, New Cumberland, PA 17070. He is married to mother. 4. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Samantha E. Ciccocioppo Daughter Dominic A. Ciccocioppo Son 5. The relationship of the Defendant to the child is that of Father. The Defendant currently resides with the following persons: NAME RELATIONSHIP Stacy (last name unknown) Paramour 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because Mother has been the primary care giver of the children since birth. 8. Each parent whose parental rights to the child have not been terminated, and the person who has physical custody of the child, have been named a party to this action. WHEREFORE, Plaintiff requests the Court to grant her custody of the children. Respectfully submitted, Date: q 1410 FRIEDMAN & KING, P.C. 'chard S. Friedman, Esquire 3820 Market Street Camp Hill, PA 17011 (717) 236-8000 Attorney for Plaintiff VERIFICATION I, Kimberly H. Ciccocioppo, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Custody Complaint; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Dated: September 2008 Kimberly H. ocioppo ' Al p v F't j __ f r C?a KIMBERLAY H. CICCOCIOPPO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-5314 CIVIL ACTION LAW FRANCIS A. CICCOCIOPPO IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, September 09, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 14, 2008 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 VINVA'MNN3d kknor ? 4 9 h .Z Kd 01 d3S 80OZ A iONQ'''k 3RI ?O KE K' KIMBERLY H. CICCOCIOPPO, Plaintiff V. FRANCIS A. CICCOCIOPPO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO-.,700i-5,51Y CIVIL ACTION - LAW CUSTODYNISITATION ACCEPTANCE OF SERVICE I hereby accept service of the Custody Complaint and Order on behalf of the Defendant, Francis A. Ciccocioppo, being authorized to do so. Dated: R - (7 - A Timothy J. , E . Attorney for Defendant C3 C ` -r OU 13 20086i KIMBERLY H. CICCOCIOPPO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-5314 CIVIL ACTION - LAW FRANCIS A. CICCOCIOPPO, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 14th of October, 2008, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, J cqu e M. Verney, Esquire, Custody C ciliator // r--> C) 1 , " y c: - . S4t:.' C 1 4TA • '?-,., fem. "1 OCT 17 2008 G KIMBERLY H. CICCOCIOPPO, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2008-5314 FRANCIS A. CICCOCIOPPO, CIVIL ACTION - LAW Defendant : CUSTODYNISITATION ORDER AND NOW, this -Z I- day of _, 2008, upon stipulation of the parties, it is hereby ORDERED and DECREED that the terms, conditions and provisions of the attached Stipulation for custody entered into by the parties, and executed by the parties and their counsel, are adopted as an Order of Court. DISTRIBUTION: ?Richard S. Friedman, Esq., 3820 Market Street, Camp Hill, PA 17011, (717) 236-8000 e-m il: friedmanandking-nhotmail.com Timothy J. Colgan, Esq., 130 W. Church Street, Suite 100, Dillsburg, PA 17019 A. Copl'es rofar fob -1 BY THE COURT- LLJ iE- CC ty C= .? CV